Notice Re: Co-Reg Filings with S/C ID's

Investment companies with series and class (contract) requirements ("S/C Funds") should take note of the following guidance concerning submitting co-registrant filings with series/class (contract) identifiers (s/c id's) to ensure that s/c id's are attributed to the CIK of the intended S/C Fund.

Adding new s/c id's. In the EDGAR system, new s/c id's may be added only to the S/C Fund CIK that is designated as the primary registrant in a co-registrant submission; the EDGAR system does not allow the addition of new s/c id's to any of the other co-registrants included on the submission.

If a filer wishes to add new s/c id's to co-registrants other than the primary co-registrant, the filer must not submit the filing as a co-registrant submission. Instead, the filer should make the same submission multiple times, individually under each co-registrant's CIK.

We suggest that filers who would have made co-registrant submissions include in their cover letter the fact that the filings are co-registrant filings that are being submitted individually under each included CIK.

Use of the "ALL" button. The "ALL" button on those EDGARLink screens for including existing s/c id's is only applicable to the existing series and/or classes that belong to the primary co-registrant. For each co-registrant other than the designated primary co-registrant, the filer must not use the "ALL" button but instead include the existing s/c id's one at a time.